“disallowance under section 14A”

THE BOMBAY DYEING AND MANUFACTURING COMPANY LIMITED,MUMBAI vs. INCOME TAX CENTRAL CIRCLE 2(1)(1), MUMBAI, MUMBAI

In the result, the appeal filed by the assessee is hereby allowed for statistical\npurposes

Bench: Shri Om Prakash Kant, Jm\Nand\Nms. Kavitha Rajagopal, Am\N\Nita No.5274/Mum/2025\N(Assessment Year: 2018-19)\Nm/S. The Bombay Dyeing And\Nmanufacturing Company Limited,\Nneville House, Jn Heredia Marg,\Nballard Estate,\Nmumbai - 400 001\Npan: Aaact2328K\Nvs.\Nnational Faceless Appeal Centre,\Ndelhi (Deputy Commissioner Of\Nincome Tax, Central Circle-2(1)(1),\Nmumbai - 400001\N(Appellant)\N(Respondent)\Nassessee By\N:\Nshri Yogesh Thar, A.R.\Nms. Sukanya Jairam, A.R &\Nshri Saurabh Surana, A.R.\Nrespondent By\N:\Nshri Leyaqat Ali Aafaqui, Sr. Ar\Ndate Of Hearing\N:\N22.12.2025\Ndate Of Pronouncement\N:\N18.03.2025\Norder\Nper Kavitha Rajagopal, J M:\Nthis Appeal Has Been Filed By The Assessee, Challenging The Order Of The Learned\Ncommissioner Of Income Tax (Appeals) [‘Ld. Cit(A)' For Short], National Faceless\Nappeal Centre (‘Nfac' For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'),\Npertaining To The Assessment Year (‘A.Y.' For Short) 2018-19.\N2.\Nthe Assessee Has Raised The Following Grounds Of Appeal:\N“1. Ground No. 1: Disallowance Of Rs. 4,65,28,171/- Under Section 14A Of The\Nact:\N1.

equity instruments are capable of yielding exempt dividend income and long-\nterm capital gains;\nd) For the purposes of computation of disallowance under Section 14A of the Act,\nthe fair market value of the investment was required to be considered, as opposed\nto the cost of investment adopted

M/S. BANK OF AMERICAN , N.A,MUMBAI vs. THE JT DIT (I.T)3, MUMBAI

In the result, the appeal by the assessee is partly allowed

held that where assessee's\nown funds and other non-interest bearing funds were more than the\ninvestment in tax-free securities, no disallowance under section 14A of the\nAct can be made. We further find that the Hon'ble Supreme Court in South\nIndian Bank Ltd. v/s CIT, reported

THE DY DIT (I.T) 1(1), MUMBAI vs. M/S. BANK OF AMERICA N.A., MUMBAI

In the result, the appeal by the assessee is partly allowed

held that where assessee's\nown funds and other non-interest bearing funds were more than the\ninvestment in tax-free securities, no disallowance under section 14A of the\nAct can be made. We further find that the Hon'ble Supreme Court in South\nIndian Bank Ltd. v/s CIT, reported

APCOTEX INDUSTRIES LIMITED,RAIGARH vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 15(1)(1), AAYAKAR BHAWAN, MUMBAI

In the result the appeal filed by the assesse stands partly allowed

Bench: Smt. Beena Pillai ()

Ld.AR submitted that the assessee had invested in equity- oriented mutual funds and equity instruments which yielded exempt income. While computing the disallowance under section 14A, the assessee had suo motu disallowed a sum of ₹63,03,077/- being the portfolio management service (PMS) fees paid, along with ... costs for the purposes of section 14A read with Rule 8D. 4.3. The Ld.AR further submitted that the Ld. AO, while computing the disallowance under section 14A read with Rule 8D(2)(ii), considered the average monthly total deposits and, on that basis, computed the disallowance

DCIT CENTRAL CIRCLE-5(4), MUMBAI vs. SATYAM REALTORS PRIVATE LIMITED, MUMBAI

In the result, the appeal of the revenue bearing ITA No

Bench: Shri Anikesh Banerjee & Shri Jagadishdcit Cc-5(4), Mumbai Vs Satyam Realtors Private Ltd. Room No.436, 4Th Floor, Room No.4, 3Rd Floor Capri, Anant Kautilya Bhawan, Bandrakurla Kanekar Marg Bandra (East) Complex, Mumbai-400051 Mumbai-400051 Pan:Aaccs7290P Appellant Respondent Assessee By : None, Respondent By : Shri Arun Kanti Datta (Cit Dr) Date Of Hearing : 09/03/2026 Date Of Pronouncement : 13/03/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Revenue Was Preferred Against The Order Of The Ld. Commissioner Of Income Tax (Appeal)-53, Mumbai [For Brevity The “Ld. Cit(A)”], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2017-18, Date Of Order 24.09.2024. The Impugned Order Emanated From The Order Of The Ld. Assistant Commissioner Of Income Tax

date of order 28.12.2019. 2. The revenue has taken the following grounds: “1. The Ld. CIT(A) erred in deleting the disallowance under section 14A r.w.r.8D(2) of the Income Tax rules by holding that investment which yielded exempt income are only to be considered for the purpose of disallowance

ASST. COMMISSIONER OF INCOME TAX, MUMBAI vs. RELIANCE RETAIL LIMITED, MUMBAI

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

relevant assessment year and restricted the deduction to Rs. 5,94,89,560/- while disallowing Rs. 6,36,64,216/-. iii. Disallowance under section 14A The assessee made suo motu disallowance under section 14A amounting to Rs. 10,73,211/- towards expenditure relatable to exempt income. The Assessing Officer ... Transfer Pricing Officer. On merits, the CIT(A) granted relief to the assessee on the issues relating to deduction under section 80JJAA, disallowance under section 14A, treatment of AJIO marketing expenditure and addition on account of creditors written back. The disallowance under section decided against the assessee. 6. Aggrieved

RELIANCE RETAIL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 8(1)(1), MUMBAI

In the result, the appeal filed by the Revenue is dismissed,\nwhereas the appeal filed by the assessee is partly allowed

relevant assessment\nyear and restricted the deduction to Rs. 5,94,89,560/- while\ndisallowing Rs. 6,36,64,216/-.\niii. Disallowance under section 14A\nThe assessee made suo motu disallowance under section 14A\namounting to Rs. 10,73,211/- towards expenditure relatable to\exempt income. The Assessing Officer ... Transfer Pricing Officer. On merits, the CIT(A)\ngranted relief to the assessee on the issues relating to deduction\nunder section 80JJAA, disallowance under section 14A,\ntreatment of AJIO marketing expenditure and addition on\naccount of creditors written back. The disallowance under section\n80G and certain other issues relating